TCC Global

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Modern slavery statement

VOLUNTARY SLAVERY AND HUMAN TRAFFICKING STATEMENT

TCC Global N.V. is making a voluntary modern slavery and human trafficking statement relating to section 54 of the UK Modern Slavery Act 2015.

Slavery is illegal worldwide, yet as of 2020 Anti-Slavery International estimated that some 40 million people globally were trapped in modern slavery, including over 10,000 in the UK alone. Of individuals trapped in slavery, some 25% were estimated to be children.

TCC fully supports the UK Government’s objective of eradicating modern slavery and human trafficking. As a business, we are strongly committed to improving our practices to combat slavery and human trafficking, and to eradicate these abuses in all their forms. TCC Global endeavours at all times to act responsibly and to deliver excellence in product and service to its customers. Modern slavery and human trafficking, in all their forms, are entirely antithetical to our values of Truth, Respect, Collaboration and Care.

Organisational structure

We are a global loyalty marketing business, providing loyalty campaigns principally in the FMCG, retail and oil retail sectors. TCC Global N.V. is the group’s parent company. TCC has over 600 employees worldwide and operates offices in 29 countries. TCC has a global annual turnover of circa €500 million.

Our business

Our business is organised into both regional and functional business units.

Our supply chains

Our supply chains include relationships with manufacturers and suppliers in China, Europe, South Asia and the Asia-Pacific. To fulfil its loyalty marketing activities, TCC procures general merchandise from manufacturers and suppliers, including toys, dinnerware, cookware, electronics, bags and luggage, textiles, glassware and cutlery.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Supplier Code of Conduct (Supplier Code) reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.

Our Supplier Code prohibits our suppliers from making use of child labour or prison or forced labour. Our suppliers also commit to treating their workers with respect and dignity, preventing abuse, harassment or discrimination, and commit to providing fair compensation, a healthy and safe working environment, and permitting freedom of association. Our Supplier Code also includes provisions relating to compliance with laws, limits on working hours and environmental compliance. Our suppliers commit to disclosing information on any subcontractors and permitting the Group access to production facilities.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk, we ensure all our suppliers sign our Supplier Code and are subject a valid third-party ethical audit confirming compliance with relevant international standards (i.e. BSCI, Sedex, WRAP or similar) prior to tcc entering into any business relationship or making any orders.

Potential suppliers in high-risk countries, as identified by the World Bank’s Worldwide Governance Indicators, are subjected to additional audit requirements before being approved as a TCC supplier. For instance, we audit our Bangladeshi suppliers’ compliance with the ACCORD scheme, focusing on fire, structural and electrical safety.

After the commencement of our business relationship, our suppliers are subjected to an ethical audit by a third party on an annual basis.

We have in place systems to:

- Identify and assess potential risk in our supply chains.

- Mitigate the risk of slavery and human trafficking occurring in our supply chains.

- Monitor potential risk areas in our supply chains.

Supplier adherence to our values and ethics

We have zero tolerance for slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values and ethics we have in place a rigorous supply chain compliance programme and a dedicated compliance team.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide social compliance training to all our staff within the supply chain team upon joining.

Our effectiveness in combating slavery and human trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

- 100% of TCC suppliers signing the Supplier Code before any orders placed

Further Steps

Our supply chain compliance programme is under constant review to help ensure a zero tolerance approach to slavery and human trafficking.

This voluntary statement is made in connection with section 54(1) of the UK Modern Slavery Act 2015 for the financial year ending 31 July 2020.

It was approved by the board on 19 February 2020.

Simon Hay

CEO

TCC Global N.V.